If employees are required to provide proof of COVID-19 vaccination or a timely negative COVID-19 test, and/or wear a mask as a condition of employment (COVID-19 Policies), and an employee is terminated for violating a...more
9/22/2021
/ COBRA ,
Coronavirus/COVID-19 ,
Employee Benefits ,
Employees ,
Employer Liability Issues ,
Employer Mandates ,
Employment Policies ,
Executive Compensation ,
Health and Welfare Plans ,
Hiring & Firing ,
Notice Requirements ,
Severance Agreements ,
Severance Pay ,
Vaccinations
As discussed in our prior blog post, the American Rescue Plan Act of 2021 (ARP) requires employers that sponsor group health plans to provide a 100% COBRA subsidy for “Assistance Eligible Individuals” during the “Subsidy...more
The American Rescue Plan Act of 2021 (ARPA), which was signed into law by President Biden on March 11, 2021, includes COBRA subsidy provisions that are significant – both for the individuals who will become eligible for COBRA...more
3/16/2021
/ American Rescue Plan Act of 2021 ,
Biden Administration ,
COBRA ,
Coronavirus/COVID-19 ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
Health and Welfare Plans ,
Health Insurance ,
New Legislation ,
Notice Requirements ,
Relief Measures
As described in a prior blog post, last spring the Department of Labor and the Department of the Treasury (Agencies) issued COVID-19 pandemic relief that extended numerous deadlines under ERISA and the Internal Revenue Code...more
3/2/2021
/ Benefit Plan Sponsors ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Filing Deadlines ,
Health and Welfare Plans ,
Internal Revenue Code (IRC) ,
IRS ,
Relief Measures ,
Retirement Plan ,
Time Extensions ,
U.S. Treasury
As noted in our prior blog post, the Consolidated Appropriations Act, 2021 (the Act) includes several types of relief for flexible spending accounts (FSAs), impacting both health FSAs and dependent care FSAs. The FSA relief...more
On May 12, 2020, the Internal Revenue Service (IRS) issued Notice 2020-29 (the Notice), an important piece of guidance for employers that sponsor health & welfare plans.
The Notice provides much-needed flexibility for...more
On May 12, 2020, the Internal Revenue Service (IRS) issued Notice 2020-33 (the Notice), which increases the maximum health flexible spending account (FSA) carryover limit. The Notice also addresses a gap in existing guidance...more
5/21/2020
/ Cafeteria Plans ,
Carryover Basis ,
Coronavirus/COVID-19 ,
Employee Benefits ,
Flexible Spending Accounts ,
FSA ,
ICHRA ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Popular
As described in our May 1 blog post, the Department of Labor (DOL) and the Internal Revenue Service (IRS) recently issued guidance (the “Extension Guidance”) providing relief to benefit plan sponsors and participants for...more
As of March 20, 2020, there has been no legislation or IRS guidance allowing plan sponsors to permit cafeteria plan participants to make COVID-19 related mid-year election changes, other than those which also meet the current...more